(1.) THE question referred to us in these references under S. 256(1) of the INCOME TAX ACT, 1961, is :
(2.) IN these references, we are concerned with the asst. yrs. 1963 -64 and 1965 -66. Proceedings under S. 271(1)(c) of the Act having been initiated, the AAC imposed a penalty of Rs. 1, 14,425 for concealment of income in the asst. year 1963 -64 and Rs. 2,50,000 for the asst. year 1965 -66. The Tribunal, on appeal, set aside the order of the AAC holding that the charge of concealment against the assessee had not been established. Hence, the present references to us at the instance of the Revenue.
(3.) THE order of the Tribunal is annexure -C to the statement of the case. The matters relating to the two asst. yrs. 1963 -64 and 1965 -66 with which we are concerned in these references have been dealt with by the Tribunal at paragraphs Nos. 6 to 8 and 14 to 17.